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SHIELDS v. UNITED STATES

Civ. A. No. C-62-584.

265 F.Supp. 770 (1965)

Sebough S. SHIELDS, Plaintiff, v. UNITED STATES of America, Defendant.

United States District Court N. D. Ohio, E. D.

March 31, 1965.

Attorney(s) appearing for the Case

William F. Snyder, Marshman, Hornbeck, Hollington, Steadman & McLaughlin, Warren M. Briggs, Cleveland, Ohio, for plaintiff.

Merle M. McCurdy, U. S. Dist. Atty., Cleveland, Ohio, Stephen K. Cochran, Dept. of Justice, Washington, D. C., for defendant.

FINDINGS OF FACT AND CONCLUSIONS OF LAW

BATTISTI, District Judge.

FINDINGS OF FACT

1. On March 18, 1952, Carl and Nancy Shields filed a joint income tax return for the taxable year 1951. The return showed a net income of $26,313.40 and a tax of $7,511.76.

2. On June 8, 1954, the Commissioner of Internal Revenue sent a notice of deficiency to the Carl Shields in which it was asserted that the Shields had understated their gross income for...

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